Posts by: RF Report


Taiwan: MoF clarifies profit-seeking enterprises tax return attachments 

Taiwan’s Ministry of Finance, in a notice on 23 December 2025, explained that profit-seeking enterprises with a special fiscal year that file profit-seeking enterprise income tax returns shall, except for those exempted from submitting tax return forms and related attachments under the relevant regulations, submit the required attachments before the filing deadline. For returns audited...

Russia updates list of jurisdictions for automatic CbC report exchange

The Federal Tax Service (FTS) of Russia has revised the list of jurisdictions that automatically exchange Country-by-Country (CbC) tax reports. The changes were issued in Order No. ЕД-7-17/884 on 11 December 2025. The updated list now covers 60 countries and 6 territories. Added Jurisdictions Removed Jurisdictions Antigua and Barbuda Anguilla Armenia Bermuda Aruba British Virgin...

US: Treasury, IRS offers safe harbour for taxpayers claiming carbon capture credit

The US Department of the Treasury and the Internal Revenue Service provided guidance on 19 December 2025 for taxpayers claiming the tax credit for carbon capture and sequestration, which was expanded and modified in the One, Big, Beautiful Bill. Notice 2026-01 provides a safe harbour for taxpayers that wish to claim the credit for qualified...

Netherlands: MoF consults proposed amendments to mutual fund regulation

The Dutch Ministry of Finance initiated a public consultation on 15 December 2025 regarding draft legislation addressing practical issues arising from the 1 January 2025 changes to the mutual fund regime for the funds for mutual account (fonds voor gemene rekening or FGR). The consultation outlines proposed legislative amendments to the Dutch Corporate Income Tax...

Hungary consults draft decree to advance global minimum tax

Hungary’s Ministry for National Economy initiated a public consultation on a draft ministerial decree on 13 December 2025 to establish the detailed implementation rules for reporting, filing, and payment obligations under the global minimum tax (Pillar 2)  for large multinational and domestic corporate groups. The draft decree details mandatory registration and reporting requirements, including the...

Australia: ATO announces GIC, SIC rates for Q3 2025-26

The Australian Taxation Office (ATO) announced the general interest charge (GIC) rates and shortfall interest charge (SIC) rates for the third quarter of the 2025-26 income year on 9 December 2025. For the quarter commencing on 1 January 2026, the GIC annual rate is set at 10.65%, and the SIC annual rate is set at...

Luxembourg implements 2026 Budget Bill

Luxembourg has enacted the 2026 budget bill following its adoption by parliament. The full budget bill was published in the Official Gazette on 19 December 2025. The government has finalised the Law of 19 December 2025, introducing targeted changes to personal income taxes and excise duties for the 2026 fiscal year, with a focus on...

Argentina: ARCA raises transfer pricing reporting thresholds

Argentina’s Federal Tax Administration (ARCA) has increased the revenue thresholds that trigger mandatory transfer pricing documentation, aiming to streamline reporting requirements for multinational and local taxpayers. The changes are set out in General Resolution 5798/2025, published in the Official Gazette on 16 December 2025. Reporting Type Previous Threshold New Threshold Notes International intermediaries (Article 41,...

Egypt: MoF increases transfer pricing documentation threshold

Egypt’s Ministry of Finance (MoF) has issued Minister of Finance Decision No. 534 of 2025 of 17 December 2025, revising the rules for transfer pricing (TP) documentation. Under the decision, the annual related-party transaction threshold for TP reporting has been raised to EGP 30 million from EGP 15 million. Companies with transactions below this level...

Japan, Kyrgyzstan sign new income tax treaty

Japan and Kyrgyzstan signed a new tax treaty on 19 December 2025 to eliminate double taxation on income and strengthen measures against tax evasion and avoidance. The treaty updates rules on the taxation of business profits and investment income, introduces anti-abuse provisions, and reinforces the exchange of information between tax authorities. Both governments said the...